The final section of this Chapter considers two sets of anti-avoidance provisions which specifically apply, or have applied, to exchange gains and losses that arise to companies under their loan relationships and derivative contracts.

The first set of provisions comprises the risk transfer scheme legislation that was enacted by the Finance Act 2010. This legislation applies to accounting periods of companies that begin on or after 1 April 2010, with accounting periods straddling that date being treated as two periods for these purposes. The risk transfer scheme legislation restricts tax relief for certain exchange losses that arise under transactions covered by the legislation.

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